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2019 (6) TMI 1262 - GUJARAT HIGH COURTDisallowance of Animal Breeding Expenses - nature of expenses - revenue or capital expenditure - HELD THAT:- The question, as raised, is no longer res integra in view of the decision of this Court in the case of Principal Commissioner of Income Tax 2, Vadodara vs. Gujarat Cop, Op. Milk Marketing Federation Ltd. [2018 (10) TMI 1385 - GUJARAT HIGH COURT] as held the activities carried under the said programme were all aimed at fertility improvement amongst milk animals. As part of the programme, the typical reasons for infertility such as improper practice in calf rearing, low body weight of animals, lack of nutrition/mineral, poor health condition, lack of awareness amongst farmers about improved breeding practices etc. In furtherance of such objectives, assessee would hold camps for village awareness, in select villages would carry out tagging and registration of animals, would hold fertility camps, would carry out mass deworming programmes, would distribute mineral mixture, carry out vaccination at mass scale, provide balanced cattle feed etc. The expenditure was general in nature and aimed at improving the practices for better fertility amongst milk animals by addressing the issues which caused infertility. The expenditure therefore was for the purpose of its business and would not be co-relatable to any tangible returns which can be expected out of such expenditure. - Decided against revenue
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